Impact Assessment for vape ban doesn't assess the impact

I've been reading about the Impact Assessment for the proposed vaping ban. It is very poor and quite weird. It doesn't seem to know what the ban is supposed to achieve and certainly doesn't seem confident that it will achieve anything. I've written about it for The Critic...

 

Vapers going back to smoking is by far the most likely consequence of the vaping ban, especially since it will be accompanied by a tax on e-cigarettes that will double the cost of vaping, and the possibility of a ban on various flavours. And for what? DHSC admit in the Impact Assessment that “we cannot conclusively say whether these policy options will impact smoking, heated tobacco product, or vaping prevalence or consumption, and therefore whether there will be an improvement on health.” It puts the cost of the various new restrictions at £531.8 million, mostly from businesses having to put up new signs and train employees, while the benefits are priced at £0 because DHSC have no idea what the consequences will be. I never thought I’d say this about a government department, but you have to admire their honesty.

 

Do go read it all.

 

I could have written much more about this, and probably will, but here's an example of the barrel scraping that went on. Unable to find an example of non-trivial harm from vaping, the authors turn to an unpublished document from Canada...

 

In the Government of Canada regulatory impact analysis statement for the Tobacco and Vaping Products Act it was assumed that the mortality and morbidity risks associated with vaping are 20% of the mortality and morbidity impacts of cigarettes. This assumption was developed with members of an expert panel composed of five academics in tobacco control.

 

Who cares? Canadian health experts reckon it's dangerous to have more than two alcoholic drinks a week. No one knows what this piece of paper written in 2017 said and it doesn't matter. I've never even heard anyone clam that vaping is only 80% safer than smoking before. We have our own estimate from UK experts and they all say vaping is more than 95% safer. And they published their work so everyone can read it. 

 

Taking the evidence that each person who does not take up smoking gains 1.0 QALY, we could therefore estimate the number of lifeyears gained for each young person that does not take up vaping to be 0.2, or £14,000 in monetary terms. Additionally, taking the evidence that each person who quits smoking is equivalent to 0.74 QALYs, we could therefore estimate the number of life years gained for each person that quits vaping to be 0.148, or £10,000 in monetary terms.

 

You could but it would be mental. 

 

Fortunately, DHSC resisted the urge to quantify the "benefits" of people quitting smoking in this way, or at all. But nor did they quantify the costs of people quitting vaping to start smoking. Despite working on this since October, the Impact Assessment is a shambles.

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